Dear Sir / Madam - I believe it will be costly to require advisors to have a surprise audit simply because they can deduct management fees from a client's account. I also believe that advisors who utilize an independent and "qualified" custodian should not be required to have such an audit.

Obviously, this proposed change in regulation is a direct result of the actions of Bernie Madoff.

As such, you should focus on the true custodial risk — an advisor using an affiliated / non-independent custodian.